Boyett v. Texas (original by judge alcala)Annotate this Case
Appellant Crystal Boyett contended the court of appeals erred by upholding the trial court’s denial of her request for a formal determination of her competency to stand trial for manslaughter. Appellant was speeding excessively when she caused a collision with another car that was occupied by three women. Two were killed; one was seriously injured. The State charged appellant with manslaughter for one of the deaths. Appellant pleaded not guilty, and the case proceeded to trial, at which appellant was convicted and sentenced to twenty years in prison. The trial court found that there was “not sufficient evidence to support a finding of incompetence,” and it declined to undertake a formal competency trial aided by expert evaluation. The court of appeals affirmed the trial court’s decision. The Texas Court of Criminal Appeals reversed, finding the court of appeals improperly considered evidence of appellant’s competency rather than considering only evidence of her incompetency, and it mistakenly applied a more burdensome evidentiary standard than the “some evidence” standard required by the applicable statute. Because appellant was convicted and sentenced in this case, the case was remanded to the trial court for it to determine the feasibility of a retrospective formal competency trial and, if feasible, to conduct such an inquiry.